You Are Accountable for a Partner You Never Evaluate: Franchised Provision and the Course-Evaluation Oversight Gap

Bottom line up front: When a university franchises or validates its award to a partner provider, the standards of the European Higher Education Area, and every national regulator that implements them, hold the degree-awarding body responsible for the quality of that provision — wherever and by whomever it is delivered. Yet the awarding institution's course-evaluation machinery — its instrument, its response-rate norms, its closing-the-loop process — almost always stops at its own campus. The students most exposed to weak provision are the ones you hear from least. That is not a hypothetical risk: in the UK it has already produced fraud, financial loss, and a National Audit Office investigation.

This is a distinct problem from the ones we have written about before. It is not the comparability of a university's own multi-campus or transnational sites, and it is not the shared quality assurance of a joint programme across an alliance. It is the oversight of a separate legal entity delivering your award under a franchise or validation agreement — and the evaluation blind spot that usually comes with it.

The responsibility does not transfer with the teaching

Franchising (a partner delivers your programme) and validation (you award for a programme a partner designs and runs) both rest on a principle that quality-assurance frameworks state plainly: delegating delivery does not delegate accountability. Under the Standards and Guidelines for Quality Assurance in the EHEA (ESG), an institution is responsible for the quality of its provision and for the students on it, including where delivery is shared with partners. National regulators reinforce this: the awarding body must be able to evidence that the student experience and academic standards at the partner match its own. As we set out in what the ESG actually require of student feedback, gathering and acting on student voice is a core expectation — and nothing in the ESG says it applies only to students taught on your home campus.

So the compliance question is uncomfortable but simple: if your regulator asked to see the course-evaluation evidence for your franchised students, disaggregated from your own and comparable to it, could you produce it? For many institutions the honest answer is no.

Why the gap is dangerous, not just untidy

Franchised and validated students are frequently the population a quality system should watch most closely. They are more likely to be studying at smaller providers with thinner student support, more likely to come from widening-participation backgrounds, and — on sector data — more likely to withdraw. These are precisely the students whose voice is easiest to miss through differential non-response: if the partner runs a low-effort survey, or none, the awarding body sees a blank where it most needs a signal.

The UK made the consequences concrete. The National Audit Office reported in January 2024 that in 2022/23, 53% by value of the £4.1 million of student-finance fraud detected by the Student Loans Company occurred at franchised providers — even though franchised students were only about 6.5% of SLC-funded students. The SLC had challenged 3,563 suspicious applications, across ten providers, associated with £59.8 million of student funding. The NAO's conclusion was that governance and oversight of franchised provision needed strengthening. Fraud is the extreme symptom, but it grows in the same soil as an unheard student experience: a partner the awarding body does not, in practice, see clearly.

The counterargument: "the partner runs its own evaluation"

This is the standard reassurance, and it is exactly the shape of the problem. Three responses.

You cannot assure quality on evidence you neither control nor can compare. If the partner uses a different instrument, a different scale, and a different cadence, you cannot benchmark their students against yours or across partners. As we have argued about comparing scores across contexts, a 4.1 here and a 4.3 there are not comparable unless the measurement is. Delegated evaluation with no common frame is not oversight; it is a hope.

Response rates and method are usually worse at the partner, not better. The awarding body's response-rate and non-response norms rarely travel to a franchise. A partner under commercial pressure has little incentive to surface bad news to the institution that can terminate the contract — a conflict of interest baked into the arrangement.

Regulatory accountability is not delegable. When something goes wrong, the regulator comes to the awarding body. "Our partner handled evaluation" is not a defence; it is an admission of the gap.

The fair counter-point in the partner's favour is real and worth stating: partners are closer to their students and can run more responsive, contextual feedback than a distant head office. The answer is not to strip partners of local evaluation but to add a common, comparable layer the awarding body owns — local depth plus central comparability, not one or the other.

What partnership-inclusive evaluation actually requires

Four practical commitments close most of the gap:

1. A common instrument, or a demonstrably equivalent one, run across all partners so results are comparable to home provision and to each other.
2. Comparable response-rate expectations and administration, so a partner cannot meet the letter of the requirement with a survey nobody answers.
3. Disaggregated, partner-level reporting visible to the awarding body — not a blended average that hides a failing site inside a healthy institutional mean, the classic aggregation trap.
4. Closing-the-loop that crosses the organisational boundary, so actions are tracked and evidenced at the partner, not just promised in a contract.

The friction is real: partners have different systems, sometimes different languages, and limited administrative capacity. That is where the delivery model matters. Koji for Education is built to deploy the same AI-moderated conversational evaluation across multiple sites and languages with minimal local overhead, then report at programme and partner level so the awarding body can see each partner's student experience distinctly and comparably — while thematic analysis surfaces why a partner's students are struggling, not merely that a number dipped. Consistent AI moderation removes the "every partner administers it differently" problem that undermines comparability. (Because the main Koji platform runs the same engine, groups operating across education and other regulated services can standardise how they hear from people wherever delivery sits.)

Franchised and validated provision can be excellent, and it widens access in ways the sector needs. But you remain accountable for it, and you cannot be accountable for what you cannot hear. The awarding body that can see its partners' students as clearly as its own is not just better protected against the next NAO headline — it is running the quality system the ESG assumed it already had.

Frequently asked questions

Who is responsible for the quality of franchised or validated provision? The degree-awarding body. Under the ESG and national regulators, delegating delivery to a partner does not delegate accountability for academic standards or the student experience.

Why is course evaluation a particular weak point in franchised provision? Because the awarding body's evaluation instrument, response-rate norms, and closing-the-loop processes usually stop at its own campus, leaving partner students — often the most at-risk — the least heard.

What did the NAO find about franchised higher education? The National Audit Office reported in January 2024 that 53% by value of £4.1m of student-finance fraud in 2022/23 was at franchised providers, though those students were about 6.5% of SLC-funded students, and concluded oversight needed strengthening.

Isn't it enough that the partner runs its own evaluation? Not for assurance. Without a common or equivalent instrument and comparable administration, the awarding body cannot benchmark partner students against its own, and the partner may have little incentive to surface problems.

How is this different from evaluating multi-campus or joint programmes? Multi-campus concerns a university's own sites; joint programmes concern shared awards across an alliance. Franchised and validated provision involves a separate legal entity delivering your award, which the awarding body must oversee but rarely evaluates directly.

How does Koji help awarding bodies evaluate partner provision? Koji deploys the same conversational evaluation across partners and languages with low local overhead, and reports at partner and programme level with thematic analysis — giving the awarding body comparable, disaggregated visibility of each partner's student experience.